Thailand Foreign Income Tax 2024: What Every Expat Needs to Know

Thailand changed the rules in January 2024. For expats who had been living there for years under the assumption that foreign income brought in after the year it was earned was untaxed, the change was material. Most of them still do not understand what it means for their specific situation.

Last updated: 09 May 2026

Thailand's Revenue Department issued Departmental Instruction Por 161/2566 in September 2023, effective from 1 January 2024. The instruction eliminated the one-year lag that had allowed Thai tax residents to bring in foreign income the following year without Thai personal income tax applying. From 2024 onwards, any foreign-sourced income remitted to Thailand by a Thai tax resident is assessable income in the year it is remitted, regardless of when it was earned.

This is not a minor technical adjustment. For European expats in Bangkok, Chiang Mai, or Phuket drawing down investments, pensions, or business income from abroad, it changes the tax position fundamentally.

Key Takeaways

• Thailand now taxes foreign income remitted in the same year it is earned. The old planning technique of parking foreign income offshore for one calendar year before remitting is no longer effective.
• You become a Thai tax resident after 180 days in Thailand in a calendar year. Part-year residents need to count carefully; the threshold is aggregate days, not continuous presence.
• LTR visa holders (Long Term Resident visa) are explicitly exempt from the new rules. This is the most significant structural planning tool available to high-income expats in Thailand.
• Double taxation agreements protect most UK, French, and German expats from double taxation, but DTAs do not eliminate the Thai filing obligation or the reporting requirement.

Who Is a Thai Tax Resident?

Thailand uses a day-count test. If you are present in Thailand for 180 days or more in a calendar year (aggregate, not continuous), you are a Thai tax resident for that year. There is no registration requirement, no visa type that automatically confers or denies resident status, and no certificate issued.

The 180-day rule applies per calendar year. A German engineer who arrives in Thailand on 5 July and stays through 31 December has spent approximately 180 days in Thailand. He is a tax resident for that year. A French expat who splits time between Bangkok (8 months) and Paris (4 months) is unambiguously a Thai tax resident.

Part-year arrivals need to count from January 1. If you were outside Thailand for the first half of the year and arrived on 1 July, you hit 180 days on 28 December. Many expats assume they are not tax residents in years they arrive or depart. That assumption is frequently wrong.

Non-residents pay Thai income tax on Thai-sourced income only, at a flat 15% withholding rate for most categories. Residents pay on all assessable income (including foreign remittances) at progressive rates from 5% to 35%.

What Changed in 2024: Por 161/2566 Explained

Before 2024, Thailand's Revenue Code taxed foreign-sourced income remitted to Thailand in the same tax year it was earned. This gave rise to a widely-used planning strategy: earn income abroad in Year 1, keep it offshore, remit it in Year 2. Because the Code taxed on remittance, and the income was earned in a prior year, the tax did not apply.

Por 161/2566 closed this gap. The instruction specifies that from 1 January 2024, foreign-sourced income remitted to Thailand by a Thai tax resident is assessable in the year of remittance, regardless of the tax year in which it was earned.

The practical effect:

• Pre-2024 foreign income held offshore and not yet remitted: the old rule applies. Remitting income that was earned before 31 December 2023 should not trigger the new assessment basis, though documentation of the earning date is essential.
• Post-2023 foreign income: the year-of-remittance equals the year-of-assessment. Bring £50,000 of investment returns into your Thai bank account in 2025, and £50,000 is assessable income for 2025.

The Revenue Department has also clarified that remittance is broadly defined. Direct wire transfers are the obvious case. But the following also count as remittances:

• Using a foreign credit card for purchases in Thailand (the credit card draw-down is treated as a remittance)
• Loan repayments received in Thailand where the loan was funded from foreign income
• Foreign debit card transactions in Thailand where the account holds foreign-sourced income
• Cross-border transfers between accounts you control

The credit card provision is particularly significant for expats who routinely use UK, French, or European cards for day-to-day spending in Thailand. Every swipe is a reportable remittance.

What Counts as Foreign-Sourced Income?

Under Thai law, foreign-sourced income broadly covers:

• Employment income from overseas employers (even if work is partly performed in Thailand)
• Pension income from UK or European pension schemes
• Investment returns: dividends, interest, capital gains from overseas accounts
• Rental income from overseas properties
• Business income from non-Thai businesses

Thai-sourced income (from Thai employment, Thai business, Thai property) has always been fully taxable for residents and is not affected by Por 161/2566.

The demarcation of "earned in Thailand vs earned abroad" becomes complicated for employees of multinational firms who work partly in Thailand and partly elsewhere. Thailand uses a day-apportionment approach for employment income: the proportion of your salary attributable to Thai workdays is Thai-sourced, the rest is foreign-sourced. For a regional executive based in Bangkok who travels frequently, this calculation requires documentation of work-location days.

Thailand's Progressive Tax Rates

Thai personal income tax applies to assessable income (net of deductions and allowances) at progressive rates:

Annual Assessable Income (THB)	Rate
0 to 150,000	Exempt
150,001 to 300,000	5%
300,001 to 500,000	10%
500,001 to 750,000	15%
750,001 to 1,000,000	20%
1,000,001 to 2,000,000	25%
2,000,001 to 5,000,000	30%
Above 5,000,000	35%

For a British expat drawing a UK pension in Thailand, the top statutory rate of 35% applies at income above THB 5 million (approximately £111,000). Most pension drawdowns in this range will be taxed between 25% and 30% effective rate on the remitted portion, depending on deductions claimed.

DTA Protection: UK, France, Germany

Double taxation agreements prevent the same income from being taxed in full by two countries. Thailand has DTAs with most major European economies including the United Kingdom, France, and Germany.

UK-Thailand DTA (1981): Article 19 covers private pensions (broadly defined). Private pension income is taxable in the country of residence, meaning a UK resident who receives a UK pension while residing in Thailand should pay Thai income tax on that pension, not UK income tax. The DTA claim requires a UK DT-Individual filing with HMRC to receive the pension gross (without UK PAYE deduction). The income is then reported in Thailand.

The UK-Thailand DTA does not cover capital gains from most asset classes, meaning Thai tax on capital gains from UK investments may apply if the gains are remitted.

France-Thailand DTA (1975): Similar private pension treatment. French pension income taxable in country of residence. But French social charges (CSG/CRDS at 9.2% for non-residents from EEA countries) are not covered by the DTA and may still apply to investment income depending on the source. French expats in Thailand should take particular care with French assurance-vie policies: the treatment of assurance-vie withdrawals under both French and Thai tax law is not straightforward.

Germany-Thailand DTA (1967): Government pensions (Beamtenpension, civil service pensions) are taxable only in Germany under the DTA, regardless of residency. Private pensions are taxable in Thailand. A German civil servant drawing a government pension while living in Thailand pays German income tax on that pension even if Thailand would otherwise tax it as a resident.

The DTA does not eliminate the Thai filing requirement. Even if the DTA allocates taxing rights to the other country, a Thai resident must still file a Thai personal income tax return (PIT Form 90 or PIT Form 91) and disclose worldwide income, claiming the DTA relief.

Failure to file is a separate offence from failure to pay. The Revenue Department has been increasing enforcement activity against non-filing expats since 2024.

The LTR Visa Exemption

The Long Term Resident (LTR) visa, introduced in 2022, is the most significant structural planning tool for high-income expats in Thailand under the new rules.

LTR visa holders who meet the "Wealthy Global Citizen" or "Wealthy Pensioner" sub-categories receive a specific tax exemption: foreign-sourced income remitted to Thailand is exempt from Thai personal income tax. This exemption applies regardless of Por 161/2566.

LTR visa requirements (Wealthy Global Citizen category):

• Assets of at least USD 1 million
• Annual income of at least USD 80,000 over the past two years
• Investment of at least USD 500,000 in Thai government bonds, Thai real estate, or Thai equities (or a combination)

LTR visa requirements (Wealthy Pensioner category):

• Age 50 or above
• Annual income of at least USD 40,000 (pension or passive income)
• Investment of at least USD 250,000 in Thai government bonds, Thai real estate, or Thai equities (alternative: annual income of at least USD 80,000 with no investment requirement)

The LTR visa is valid for 10 years (two five-year periods). For a retired British professional, age 58, with a £500,000 investment portfolio and a UK pension income of USD 50,000 per year, the Wealthy Pensioner LTR category may be accessible with a USD 250,000 Thai investment. The tax saving on pension income alone, at 25-30% effective Thai tax rate on USD 50,000 per year, is USD 12,500 to USD 15,000 annually. Against a 10-year LTR horizon, the structural benefit is substantial.

Practical Planning Strategies

Segregate pre-2024 and post-2023 offshore income. Keep funds earned before 1 January 2024 in a dedicated offshore account. Remit from that account first. Only switch to post-2023 earnings accounts once the pre-2024 balance is exhausted.

Document the earning date of all offshore assets. Bank statements, brokerage statements, and dividend records with dates are essential. The Revenue Department is unlikely to accept "I think this was earned before 2024" without supporting documents.

Stop using foreign cards for Thai spending. Each transaction is a reportable remittance. Open a Thai bank account, fund it in deliberate, documented tranches, and use a Thai card for local spending. This gives you control over both the amount and the timing of your remittances.

Review your UCITS portfolio structure. Irish-domiciled accumulating UCITS do not distribute dividends; gains accumulate inside the fund. This means no dividend remittance to Thailand and no annual income tax event. The taxable event is only on sale of units. For long-term investors in Thailand, accumulating funds reduce the annual reporting burden significantly.

Consider the LTR visa if your asset base qualifies. The investment requirement is not a cost; it is a reallocation into Thai assets that you continue to own. If the Thai government bond yield or real estate return is acceptable, the LTR exemption essentially pays for itself through the tax saving.

File your Thai PIT return, every year. The deadline is 31 March of the following year. Filing, even if little or no tax is owed, prevents the non-filing penalty and demonstrates compliance.

Common Misconceptions

"My money was earned outside Thailand, so Thailand cannot tax it." This was true before 2024 under the old interpretation. It is no longer accurate for income earned from 1 January 2024 onwards if you are a Thai tax resident.

"I hold a Thai Elite Card, so I am not a tax resident." The Thailand Elite Card is a long-stay visa, not a tax status. The 180-day count applies regardless of visa type.

"My DTA protects me from Thai tax." DTAs prevent double taxation; they do not prevent Thailand from applying its domestic rules. You still need to file a Thai return.

"I only transferred my salary to Thailand, not investment income." Employment income from an overseas employer attributable to work performed outside Thailand is foreign-sourced and assessable when remitted.

Frequently Asked Questions

Q: If I moved to Thailand in 2024 and became a tax resident, do I owe Thai tax on income earned before I arrived?

A: No. Pre-arrival income is not Thai-sourced and is generally not assessable in Thailand. The issue arises when you remit post-arrival, post-2023 income. Keep pre-arrival funds in a segregated account.

Q: Does the Por 161/2566 instruction have the force of law?

A: Departmental instructions in Thailand are binding on Revenue Department officials. In practice, the Revenue Department is enforcing on this basis and courts have upheld similar instructions historically.

Q: I am a French citizen and my income is from a French company. Does Thai tax apply?

A: If you are a Thai tax resident (180+ days in Thailand) and you remit that income to Thailand, Thai personal income tax applies subject to the France-Thailand DTA. The DTA may provide relief depending on the income category.

Q: Can I avoid Thai tax by leaving before 180 days each year?

A: Yes, mathematically. If you spend 179 days or fewer in Thailand in a calendar year, you are not a Thai tax resident for that year and the foreign income tax rules do not apply to you.

Q: Does the LTR visa tax exemption cover capital gains?

A: The LTR exemption covers all foreign-sourced income remitted to Thailand, including capital gains. This is a significant advantage for investors with large portfolios.

Related Reading

• UCITS ETFs vs US ETFs: which works for expats in Southeast Asia
• Wealth management in Malaysia: the expat's complete guide
• How currency swings can work in your favour as an expat
• Best offshore bank accounts for expats

Managing Your Portfolio Across Borders?

The 2024 Thailand tax change is the clearest example of why structure comes before investment selection. If you are an expat in Thailand, or planning to relocate there, the way your portfolio is held, how income is generated, and when remittances occur all have material tax consequences.

Book a no-obligation call with Ciprian

This content is for informational purposes only and does not constitute personalised financial, investment, or tax advice. By reading this post, you agree to our disclaimer.